by Kevin Chen, Research Assistant
Nuclear History of the Bay Area
World War II transformed the San Francisco Bay Area into a “naval lake” encircled by shipyards, bases, and other facilities. In San Francisco, two sites – Hunters Point and Treasure Island – were vital nodes within this network. The Hunters Point Shipyard serviced and repaired over 200 vessels coming to and from the Pacific Theater. Located between San Francisco and Oakland, Naval Station Treasure Island processed and trained over 4.5 million personnel during the war.
In this way, Hunters Point and Treasure Island were incorporated within trans-Pacific currents of people, ships, and militarization. With the advent of the Atomic Age, these currents came to include nuclear weapons, scientific knowledge, and radioactive fallout. On July 15, 1945, components of the “Little Boy” atomic bomb were loaded onto the USS Indianapolis at the Hunters Point Shipyard before being shipped to Tinian Island and detonated over Hiroshima. During the Cold War, the Hunters Point Shipyard and Naval Station Treasure Island took on new strategic significance as launching and return points for U.S. nuclear tests in the Pacific and as sites of radiological defense research and training. In addition to sustaining national nuclear security, these activities left a legacy of radiological contamination that continues to produce local conditions of insecurity.
Radiological Contamination of the Hunters Point Shipyard
The radiological contamination of the Hunters Point Shipyard results from three main sources: use of radioluminescent materials in ship repair, decontamination and experimentation on ships from Operation Crossroads, and radiological studies conducted by the Naval Radiological Defense Laboratory (NRDL).
Radioluminescent Materials in Ship Repair
From 1941 to 1974, the US Navy operated the Hunters Point Shipyard as a ship repair and maintenance facility. Until 1971, the Navy commonly used radioluminescent materials in ship repair and maintenance activities at Hunters Point. Paint containing radium, strontium, and promethium was applied to deck markers, watch dials, and compasses to allow personnel to see in the dark without electricity. Because they were regarded as industrial materials rather than radioactive sources, these substances did not require special licensing by the Atomic Energy Commission (AEC). As a result, waste containing radioluminescent substances was commonly dumped in landfills and discharged into drainage systems without special protection. Although the Navy was aware of the health and environmental hazards, it did not implement stricter controls for the disposal of radioluminescent materials until the 1960s. At Hunters Point, the widespread use of these materials contaminated the buildings, landfills, scrap yards, and sewer pipes where they were used, stored, and discarded. As a key repair and maintenance facility, the shipyard was also used to berth and service nuclear-powered vessels from 1966 to 1973, and again from 1985 to 1989 as a short-term annex to Mare Island Naval Shipyard. Radiological surveys have not found contamination resulting from these activities.
Operation Crossroads Ship Decontamination
In 1946, the Hunters Point Shipyard served as the launching point and return site for Operation Crossroads, a pair of nuclear tests conducted by the U.S. military at Bikini Atoll in the Pacific.  To evaluate the effects of the atomic bomb on existing military assets, the Navy placed nearly one hundred ships near the detonation site. These ships became highly radioactive after the second bomb, which was detonated underwater, generated a massive cloud of spray containing plutonium, strontium, cesium, and other radionuclides. Upon entering the detonation site, support ships also became contaminated when radioactive seawater entered piping systems and was absorbed by marine life attached to hulls. At the time, the test planners were ill-prepared to manage radiological hazards, and decontamination efforts at Bikini were ineffective in reducing radiation levels.
After Crossroads, six vessels that were too damaged to travel under their own power – Independence, Gasconade, Crittenden, Skate, Skipjack, and Hughes – were towed back to Hunters Point, where they became experimental objects for testing decontamination methods. Through trial and error, the radiation safety personnel settled on using a combination of wet sandblasting and acid solutions to decontaminate the remaining ships. Wet sandblasting removed paint, rust, and marine growth that concentrated radioactivity from ship surfaces, and acid solutions were used to flush out internal piping systems. The shipyard personnel also examined other radiological problems that the ships presented. For instance, they burned 610,000 gallons of oil that became contaminated during Crossroads to measure the amount of radioactivity in the resulting fumes. Because of the expertise developed at the shipyard, Hunters Point became the Navy’s hub for monitoring ships from Crossroads, decontaminating 12 additional target vessels and 61 support vessels by 1948.
These activities generated large amounts of radioactive waste. Although some of this waste was packaged into steel drums and dumped into the Pacific Ocean, safety protocols did not require special disposal of waste produced from the decontamination of support vessels, which were typically less contaminated than the target ships. As a result, it is possible that radioactive waste from the decontamination efforts was buried in the shipyard landfill and dumped into the San Francisco Bay.
Naval Radiological Defense Laboratory (NRDL)
Operation Crossroads and the subsequent decontamination efforts at the Hunters Point Shipyard catalyzed scientific inquiry into the emergent field of radiological defense. In 1947, the Navy established a radiation laboratory, known as the “Rad Lab,” at Hunters Point. The Rad Lab was tasked with developing decontamination methods, radiological protection equipment, and radiation detection instruments. In 1948, the Navy expanded the laboratory into the Naval Radiological Defense Laboratory (NRDL). NRDL became responsible for investigating the effects of radiation through a combined program of basic and applied research. To this end, NRDL researchers continued to use ships from Crossroads as experimental specimens and floating laboratories for radiological studies.
NRDL’s scientific program included large-scale field studies, which took its researchers far beyond the gates of the shipyard. From 1950 until the 1963 Partial Test Ban Treaty, NRDL participated in nearly every U.S. nuclear test at the Pacific and Nevada Test Sites. NRDL conducted numerous scientific studies as part of the tests. Many of these involved collecting and analyzing samples of fallout from the detonations. In 1956, NRDL began conducting field experiments that involved spreading radioactive fallout simulants across large swaths of land at Camp Stoneman and Camp Parks. The laboratory later established a permanent field station at Camp Parks near Dublin, where scientists studied the biological effects of radiation by irradiating goats, sheep, cows, and other large mammals.
Like other nuclear research facilities, NRDL generated massive amounts of radioactive waste. The laboratory obtained radioactive sources through the AEC for use in radiological studies. The laboratory also used x-ray machines, neutron generators, and particle accelerators to generate ionizing radiation. Researchers extensively used these sources and devices in biological, chemical, and physical experiments. Clothing, laboratory equipment, cleaning supplies, animal specimens, and other materials became contaminated in the routine course of experimentation. These materials and objects were designated as low-level radioactive waste, packed into 55-gallon steel drums, towed on a barge to the Farallon Islands, and dumped into the Pacific Ocean. The Hunters Point Shipyard also handled and disposed radioactive waste from the UC Berkeley, Lawrence Livermore Laboratory, and other facilities in the Bay Area until 1959. The scale of waste disposal operations was massive, with over 47,500 barrels of waste containing 13,500 curies of radioactivity estimated to have been dumped. This waste includes the wreck of the Independence, which the Navy filled with barrels of waste and sank off the Farallon Islands in 1951.
Throughout NRDL’s existence, the Health Physics Division implemented radiological safety policies and procedures to prevent contamination and limit exposure. Health physicists and medical staff managed radioactive sources in accordance with AEC policies, monitored personnel exposure, surveyed laboratory areas, and decontaminated locations where high levels of radioactivity were found. Despite these precautions and procedures, radiological contamination remains at the former buildings and sites that NRDL occupied. Although historical records suggest that radioactive waste generated by laboratory activities was disposed offsite, some waste may have been dumped into the shipyard landfill or burned in the shipyard incinerator.
Radiological Contamination of Treasure Island
The radiological contamination of Treasure Island stems from three main sources: ship repair and salvage operations during World War II, radiological defense and decontamination training, and instrument calibration training.
Ship Repair and Salvage Operations
During World War II, Naval Station Treasure Island supplemented the work of Bay Area shipyards with ship repair and salvage operations. The base processed an estimated 200,000 pounds of scrap metal per month and repaired numerous warships coming to and from the Pacific Theater. The use of radioluminescent substances like radium and thorium paint in deck markers, instrument dials, and other devices led to the contamination of shops, storage areas, salvage yards, and landfills where these materials were used, stored, and disposed.
Radiological Defense and Decontamination Training
In 1946, the Navy established the Damage Control Training Center (later renamed as the Damage Control School in 1952) on Treasure Island to maintain preparedness among naval personnel in the postwar period. After Operation Crossroads highlighted the radiological hazards of atomic warfare, the Navy directed the school to develop a course in radiological safety. On March 17, 1947, the school commenced its first, six-week-long radiological safety course that covered the science of radiation and provided practical training in using and calibrating radiation detection instruments. Personnel and faculty from NRDL and the University of California, Berkeley provided technical support for the course.
In 1956, the Navy began using the USS Pandemonium, a full-scale mockup of a patrol vessel constructed from scrap metal, in radiological safety and decontamination training. At eleven points on the ship’s deck, sealed sources of cesium-137, each emitting 0.65 curies of radioactivity, were lowered or raised with wire cables to create a radiation field. Students in the course practiced using radiation detection instruments to identify these sources of radiation. The school later began using short-lived radioisotopes in fallout simulant, which the instructors believed more closely approximated actual radiological conditions resulting from a nuclear explosion. During decontamination trainings, instructors sprayed a solution containing bromine-82 across the deck of the Pandemonium, mimicking radiological contamination from an underwater nuclear detonation. Students would then measure radiation levels using radiation detection instruments, scrub areas of elevated activity with detergent and water, and evaluate the effectiveness of decontamination efforts. Until the 1963 Partial Test Ban Treaty, instructors at Treasure Island used the Pandemonium to train and prepare radiation safety personnel for U.S. nuclear tests in the Pacific.
In 1958, Naval Station Treasure Island began offering a training course for military medical officers in the medical aspects of modern warfare. The course included a large-scale simulation of a nuclear attack on Treasure Island using a mock atomic bomb detonated with thirty pounds of TNT. During these simulations, students applied the countermeasures that they learned to personnel who pretended to suffer from radiation sickness. In conjunction with the course and simulations, NRDL and Treasure Island convened symposia on the medical aspects of modern warfare, hosting military planners, scientists, and medical experts from government and academic institutions.
These trainings generated significant amounts of radioactive waste, much of which continues to contaminate Treasure Island. Initially, runoff from the decontamination trainings on the Pandemonium, consisting of cleaning solutions and fallout simulants, was allowed to seep into the ground as it was washed off of the ship. The Navy later constructed tanks that held the runoff until it decayed to lower levels of radiation and was subsequently flushed out into San Francisco Bay. Use of short-lived radioisotopes in decontamination trainings continued until 1972, when environmental regulations imposed stricter restrictions on discharges of effluent into the Bay.
The Damage Control School also provided training on the use, calibration, and maintenance of radiation detection instruments. The use of these instruments required constant calibration with check sources and repair to ensure functionality and accuracy, especially in combat field conditions. Although these trainings were intended to reduce the risk of radiological hazards, they resulted in actual radiological crises. On January 17, 1950, 40.3 milligrams of radium sulfate were spilled in a classroom laboratory in Building 233. At the time, 18 officers were taking a course in instrument calibration. Because the radium was in the form of a light powder, contamination quickly spread throughout the building. The following day, radiation safety personnel from NRDL arrived to begin decontaminating the classroom using a specialized vacuum cleaner and to establish a makeshift decontamination center. Contaminated personnel were cleaned with soap, scrubbers, and acid solutions, and contaminated clothing and equipment were discarded as low-level radioactive waste. The cleanup effort generated more than 200 barrels of radioactive waste.
The Navy also had to contend with the contamination that was spread offsite. Immediately after the spill, people present in the building were allowed to return home, tracking radioactive particles that stuck onto their bodies and clothing. In the week following the accident, NRDL personnel painstakingly reconstructed the paths of the people who were in the building during the spill. Armed with Geiger counters, they found and removed radiation in people’s homes, far from the scene of the accident. For a year after the accident, medical personnel performed monthly blood cell counts of exposed individuals to monitor potential health effects. After two months of daily scrubbing and decontamination, the air and equipment in the classroom were still too radioactive for the building to return to regular use. The building did not regain operational clearance until nine months later.
Beyond the 1950 radium spill, instrumental calibration activities at Treasure Island produced large amounts of radioactive waste in the routine course of operations. Instrument calibration required check sources that emitted a known level of radioactivity. Recent radiological investigations conducted as part of the ongoing environmental remediation effort have turned up dozens of small foils containing radium-226 in the former solid waste disposal areas (SWDAs) on the northwest corner of the island. The Navy speculates that these items were used as check sources for RADIAC instruments in the 1940s and 1950s.
Shutting Down the Cold War
In the late 1980s, the Department of Defense (DoD) initiated the process of shutting down excess bases as the end of the Cold War reconfigured the global geopolitical order. Established by Congress in 1988, the Base Realignment and Closure (BRAC) Commission oversees this process by evaluating and selecting sites for closure. In the 1990s, the commission began shutting down the Bay Area “naval lake” by listing the long abandoned Hunters Point Shipyard for closure in 1991 and Naval Station Treasure Island in 1993.
Base closure proved to be a highly contentious issue across the nation. Many bases were highly polluted from decades of industrial use and onsite waste disposal. In 1980, Congress passed the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as Superfund, to require the cleanup of sites contaminated with hazardous waste. In 1986, the Superfund Amendments and Reauthorization Act (SARA) mandated that DoD sites fell under the jurisdiction of Superfund. The massive scale of contamination at former defense sites has complicated the closure and transfer of bases and other military installations to civilian use.
Remediating Hunters Point Shipyard
In 1974, the Navy shut down the Hunters Point Shipyard. From 1976 to 1986, the Navy leased the shipyard to Triple A Machine Shop, a commercial ship repair company. The passage of CERCLA in 1980 prompted the Navy to conduct an initial assessment of the shipyard in 1984, identifying twelve sites potentially contaminated with industrial waste. The survey estimated that 6,000 pounds of devices containing radium paint were dumped in the shipyard landfill. Because of the extent of contamination and the risk to human health, the EPA designated the shipyard as a Superfund site in 1989. In 1992, the Navy, EPA, and State of California signed a Federal Facility Agreement (FFA) to establish regulatory responsibilities. As a federal Superfund site, Hunters Point Shipyard is subject to oversight from the Environmental Protection Agency (EPA). The CaliIfornia Department of Toxic Substances Control (DTSC) plays a similar role at the state level. The California Department of Public Health (CDPH) regulates the cleanup and clearance of buildings at the sites, and the Regional Water Quality Control Board (RWQCB) enforces water quality regulations, especially with regards to groundwater.
In 1998, the Navy officially began large-scale remedial action on the shipyard. The initial remedy involved removing contaminated soil, backfilling excavated areas with clean soil, and monitoring groundwater for threats to human health and the environment. As the Navy began to remediate the shipyard, however, it began to encounter greater levels of contamination than expected. As a result of these discoveries, the Navy began to change its remediation strategy. Rather than excavate all soil contaminated with “ubiquitous metals,” the Navy decided to excavate soil with elevated levels of lead, organic chemicals, and other “non-naturally occurring” contaminants, leaving “ubiquitous metals” in place. The Navy also decided to place covers over the entire parcel to prevent exposure to the contamination that would remain in the soil. In addition, the Navy implemented restrictions on land use known as institutional controls to further limit exposure. In response to these changes, San Francisco voters passed Proposition P in 2000, a non-binding declaration requiring cleanup of the shipyard to the highest residential standards.
The discovery of widespread radiological contamination at the shipyard also complicated the remediation effort. From 1991 to 2003, the Navy completed radiological surveys of the shipyard. The initial phases focused on the extent of radium-containing devices in the shipyard landfill, with later phases investigating contamination more widely throughout the shipyard, including building and areas formerly occupied by NRDL. In 2004, the Navy completed a Historical Radiological Assessment (HRA) that identified 91 radiologically impacted sites on the shipyard. Following the publication of the HRA, the Navy initiated a radiological removal action in 2006 to remediate contamination found at these sites.
The recent scandal over soil sampling fraud committed by Tetra Tech, the contractor responsible for the majority of radiological remediation work at the shipyard, has marred the remediation process, however. In 2012, the Navy discovered discrepancies in soil sample data from Tetra Tech. In 2016 and 2017, former workers revealed that Tetra Tech had falsified soil sampling data by swapping clean soil samples for potentially contaminated samples. In 2017, the Navy concluded that Tetra Tech’s data were unreliable, finding up nearly half of soil samples in one parcel to have been potentially falsified or manipulated. The results of the data review prompted the Navy to begin resampling the areas previously remediated by Tetra Tech in 2019. The sampling fraud has caused the cost of remediation to balloon to over $1 billion, with nearly $300 million in contracts already paid to Tetra Tech.
Activists and residents have challenged the shipyard remediation process on a number of technical bases, even before the sampling fraud occurred. First, they have criticized the Navy for failing to comprehensively sample the shipyard for radioactivity. Based on historical investigations, the Navy has listed the vast majority of the buildings and sites on the shipyard as “radiologically unimpacted.” However, activists and residents contend that all parts of the shipyard, including portions that have already been transferred and redeveloped, are potentially contaminated given its history of ship decontamination. Additionally, critics have also argued that the sampling that has been conducted is flawed on multiple accounts by ignoring alpha and beta radiation and taking background radiation measurements within the shipyard. Some have argued that the Navy uses outdated and unprotective radiation standards for remediation. Activists and residents have also questioned the efficacy of the Navy’s remediation strategies, opposing the Navy’s decision to leave much of the contamination, including the highly toxic landfill, in place under “durable covers.”o
Furthermore, community members have expressed concerns over the Navy’s lack of transparency. In their opposition, residents and activists have cited the requirement in CERCLA that remediation strategies receive “community acceptance.” In 1993, the Navy created a Restoration Advisory Board (RAB) that provided community input on the remediation process. In 2009, however, the Navy disbanded the RAB over conflicts over accountability and authority. In 2000, a fire at the shipyard landfill burned for a month, releasing smoke and contaminants into the air. The EPA later fined the Navy for failing to notify the community about the incident in a timely manner. In 2018, the CDPH found a radium deck marker in Parcel A during a gamma ray scan, conducted in response to the concerns of shipyard residents and the broader community after news of the Tetra Tech sampling scandal broke. Although regulators claimed that the object didn’t present a danger to the public, critics argued that it proved the inadequacy of the remediation.
Remediating Treasure Island
Although Treasure Island underwent site evaluation in 1987, it was not designated a Superfund site by the EPA, despite receiving a Hazard Ranking System score that exceeded consideration for inclusion. As a result, the DTSC is the lead regulatory agency supervising the cleanup, as established by a 1992 Federal Facilities Agreement. The CDPH and RWQCB perform the same regulatory functions at Treasure Island as they do at Hunters Point.
Early surveys and investigations identified significant chemical contamination, including dangerously high levels of dioxins at the site of a daycare. In 2006, the Navy published a Historical Radiological Assessment (HRA) of Treasure Island that identified five radiologically impacted sites. Because Treasure Island was primarily a training site, the HRA underscored the low likelihood of radiological contamination, including in the solid waste disposal areas (SWDAs) under the housing area on the northwest corner of the island. After the publication of the HRA, however, the Navy began to unearth hundreds of low-level radiological objects (LLROs) in the SWDAs, including dozens of octagonal radium foils that the Navy speculated were used as calibration sources for radiation detection instruments during the 1940s and 1950s. These discoveries raised concerns among regulatory agencies over the adequacy of the remediation process and the potential for widespread radiological contamination on the island. In 2011, the CDPH cited Shaw Environmental, the Navy’s primary contractor for the remediation effort, for failing to conduct radiological surveys of excavated soil. In 2011 and 2013, the CDPH conducted gamma ray scans in the housing area that identified locations with elevated radioactivity outside of the SWDAs.
As a result of these findings, the CDPH pushed the Navy to revise and update the HRA, arguing that the Navy’s continued reliance on the 2006 HRA dangerously underestimated the scope of radiological contamination. In 2012, the Navy published an addendum to the 2006 HRA that identified 10 new radiologically impacted sites on the basis of new historical evidence of ship repair and salvage activities on Treasure Island during World War II. The addendum also acknowledged the possibility of residual contamination at the former sites of the Pandemonium and designated the entire housing area on the northwest portion of the island as a radiologically impacted site. In contrast to the original HRA, the addendum noted that housing construction activities from the 1960s to the 1980s likely spread radioactive objects and soil from the SWDAs throughout the housing area. In response to residents’ concerns over the radiological contamination, the Navy conducted radiological surveys inside the homes on Treasure Island in 2014. The survey found three locations of elevated gamma radioactivity that the Navy declared did not pose an significant risk to human health. These discoveries have cast doubt over the adequacy of the remediation efforts at Treasure Island and caused the cost of the cleanup to increase to nearly $300 million. In the wake of the Tetra Tech scandal at Hunters Point, community members have also voiced concerns over the integrity of Tetra Tech’s remediation work on Treasure Island.
Redeveloping Hunters Point and Treasure Island
Both Hunters Point and Treasure Island have been remade into sites of large-scale redevelopment that promise simultaneously to generate profits and promote urban sustainability. However, the obstacles that the Navy has encountered in the remediation process have revealed the enduring presence of the nuclear insecurity in the Bay Area and the difficulty, if not impossibility, of paving over the toxic legacies of the Cold War.
Redeveloping Hunters Point Shipyard
In the 1990s, the imminent closure and transfer of the shipyard to the city inspired a series of plans for transforming Hunters Point, culminating with the city’s adoption of the Hunters Point Shipyard Redevelopment Plan in 1997, which envisioned a mix of residential, commercial, and light industrial uses. In 1999, Lennar, a home construction corporation based in Miami, was selected as the master developer. Disagreements between the Navy and the City of San Francisco over the terms of land transfers, however, delayed the project until 2004, when the two parties signed a Conveyance Agreement that stipulated the phased transfer of land parcels in concert with the remediation of the shipyard. That same year, the first phase of redevelopment began with the transfer of Parcel A and the initiation of construction of 1,600 housing units. Residents began moving into the rebranded “San Francisco Shipyard” in 2014.
Throughout the redevelopment process, the changing investment environment has caused the development plan to shift. In 2007, the city began to integrate the second phase of the shipyard redevelopment project with the redevelopment of Candlestick Point, also being completed by Lennar. Formalized in the 2010 amendment to the shipyard redevelopment plan, the plan called for 10,500 units of housing and over 5 million square feet of commercial space. In addition to profits and increased municipal tax bases, the redevelopment project promises a range of economic, environmental, and social benefits for southeast San Francisco. According to proponents, the redevelopment project will benefit the local community through the creation of 18,500 jobs and $3.7 billion in economic activity. Moreover, Lennar signed a Community Benefits Agreement that ensures that over 30 percent of new housing constructed from redevelopment will be for low- and moderate-income households, $8.5 million will be invested in job training programs for local residents, and developers will participate in a local hiring program. The shipyard redevelopment project coincides with the Blue Greenway project, which aims to create parks and trails throughout southeast San Francisco to give local communities access to the waterfront and to reconnect the area to the rest of the city.
Nevertheless, difficulties from the shipyard remediation have delayed the redevelopment project. In 2016, the EPA ordered the Navy to halt transfers of land given the revelation of soil sampling fraud committed by Tetra Tech. In addition, the redevelopment project has raised concerns over displacement of existing residents in Bayview-Hunters Point, home to the largest remaining Black community in San Francisco. In addition to the issues surrounding the shipyard remediation, the redevelopment project itself has caused issues of environmental injustice. When redevelopment of Parcel A of the shipyard began, community residents raised concerns over the amount of dust generated by construction, which released naturally-occurring asbestos contained in the serpentine rock. In 2006, the Bay Area Air Quality Management District (BAAQMD) fined Lennar for failing to properly monitor dust levels. The community also raised concerns over dust from development activities associated with the planned implosion of Candlestick Park in 2015, which activists successfully challenged.
Redeveloping Treasure Island
In 1997, the year that Naval Station Treasure Island officially shut down, Mayor Willie Brown established the Treasure Island Development Authority (TIDA), a special city agency charged with managing redevelopment of the former base. The creation of TIDA facilitated the commercial development envisioned for Treasure Island by separating the project from other redevelopment projects in the city. In 2002, TIDA selected Treasure Island Community Development (TICD), a joint venture between Lennar, Kenwood Investments, and Wilson Meany, as the master developer. In the meantime, a consortium of nonprofit organizations called the Treasure Island Homeless Development Initiative (TIHDI) secured a third of the military housing for formerly homeless people in 1999. The City of San Francisco also began renting out the other units at market rates, which tended to be more affordable than other housing in the city. Because of these uses, Treasure Island became home to a significant proportion of low- and moderate-income people of color.
Throughout the 2000s, TICD put forth a series of development proposals that successively increased the amount of housing to be developed on the island. In 2011, the Board of Supervisors approved TICD’s plan, which included 8,000 housing units and over 500,000 square feet of commercial and office space. As with the Hunters Point Shipyard, disagreements between the Navy and the city over the terms of the land transfer delayed the project. In 2014, the city agreed to pay $55 million for Treasure Island, with the promise of an additional $50 million if the development project is commercially successful. The following year, the Navy transferred the first 159 acres to the city for redevelopment, and TICD began construction of infrastructure in 2016.
As with the redevelopment of the Hunters Point Shipyard, the Treasure Island Redevelopment Project promises to deliver a range of benefits to San Francisco. In addition to generating profits and increasing tax bases, the project is widely touted as a model of sustainable urban development by architects, planners, developers, and public officials alike. The project also promises to intervene in the current housing crisis by setting aside one quarter of housing for low- and moderate-income households. Despite these benefits, the Treasure Island Redevelopment Project has drawn controversy. The extent of contamination has raised questions over whether the island is or ever will be safe to live on, with many residents attributing health issues, from tumors to respiratory problems, to toxic exposure. Additionally, because Treasure Island is low-lying and built from dredged material, it is particularly vulnerable to rising sea levels and earthquakes. As a result, TICD is currently compacting the soil to improve seismic stability, adding new layers of soil to increase the land elevation, and constructing a reinforced wall around the perimeter of the island. Moreover, the development project has raised concerns among existing residents over the displacement of low-income people of color. Treasure Island is home to 2,800 people, over half of whom live below the poverty level. With 25 percent Black or African American, 23 percent Hispanic or Latino, and 18 percent Asian population, Treasure Island has also been touted as one of San Francisco’s most diverse communities. The redevelopment plan currently allows residents who moved to Treasure Island before the plan was adopted in 2011 to receive cash payment or relocation into new units. Households that moved to Treasure Island after that time, however, receive no such assistance.
 Roger W. Lotchin, “The City and the Sword: San Francisco and the Rise of the Metropolitan-Military Complex 1919–1941,” Journal of American History 65, no. 4 (March 1979): 996–102, https://doi.org/10.2307/1894557.
 United States Department of the Navy, “Hunters Point Shipyard Final Historical Radiological Assessment: History of the Use of General Radioactive Materials 1939–2003” (2004), 6-3, https://www.bracpmo.navy.mil/content/dam/bracpmo/california/former_naval_shipyard_hunters_point/pdfs/all_documents/environmental_documents/radiological/hps_200408_hra.pdf.
 Lynne Horiuchi and Tanu Sankalia, eds., Urban Reinventions: San Francisco’s Treasure Island (Honolulu: University of Hawaii Press, 2017), 14.
 For a detailed account of radiological contamination at the Hunters Point Shipyard, see U.S. Navy, “Hunters Point Shipyard Final Historical Radiological Assessment.”
 U.S. Navy, “Hunters Point Shipyard Final Historical Radiological Assessment,” 6-26—6-29.
 U.S. Navy, “Historical Radiological Assessment Hunters Point Annex: Volume I Naval Nuclear Propulsion Program 1966-1995,” (August 2000).
 For a comprehensive history of Operation Crossroads, see Jonathan M. Weisgall, Operation Crossroads: The Atomic Tests at Bikini Atoll (Annapolis, MD: Naval Institute Press, 1994).
 U.S. Navy, “Hunters Point Shipyard Final Historical Radiological Assessment,” 6-14—6-19.
 At the time, ships received final clearance when radiological readings were below 0.001 rem gamma shielded and below 0.005 rem beta-gamma unshielded. Because decontaminating the ships to levels that would be safe for scrapping was costly, the vast majority of the target vessels were scuttled at sea. On the post-Crossroads history of ships, see James Delgado, “After Crossroads: The Fate of the Atomic Bomb Target Fleet,” Journal of Maritime Archaeology 11, no. 1 (April 2016): 25-31, https://doi.org/10.1007/s11457-016-9154-7.
 Lindsey Dillon, “Crossroads in San Francisco: The Naval Radiological Defense Laboratory and Its Afterlives,” in Inevitably Toxic: Historical Perspectives on Contamination, Exposure, and Expertise, eds. Brinda Sarathy, Vivien Hamilton, and Janet Farrell Brodie, (Pittsburgh, PA: University of Pittsburgh Press, 2018), 86–89.
 Lisa Davis, “Fallout” SF Weekly, May 2, 2001, https://archives.sfweekly.com/sanfrancisco/fallout/Content?oid=2141567.
 Part of the contamination has resulted from changing radiological standards over time. When much of the laboratory moved into a new centralized building in 1955, for instance, the Health Physics Division decontaminated former buildings occupied by NRDL to a gamma contact dose rate of less than 1.8 millirem per hour. When the laboratory closed in 1969, the AEC decontaminated buildings to a gamma contact dose rate of less than 0.2 millirem per hour. Changing regulations and subsequent surveys revealed additional contamination from the laboratory.
 For a detailed account of radiological contamination at Treasure Island, see United States Department of Navy, “Treasure Island Naval Station Final Historical Radiological Assessment– Supplemental Technical Memorandum” (2014), https://www.bracpmo.navy.mil/content/dam/bracpmo/california/former_naval_station_treasure_island/pdfs/environmental/hra/TI_20140701_HRASTM_pt1of2.pdf.
 U.S. Navy, “Treasure Island Naval Station Final Historical Radiological Assessment– Supplemental Technical Memorandum,” 48.
 United States Navy, “Treasure Island Naval Station Final Historical Radiological Assessment,” (2006), 6-5—6-9, https://www.bracpmo.navy.mil/content/dam/bracpmo/california/former_naval_station_treasure_island/pdfs/environmental/TI_200602_HRA.pdf.
 Lindsey Dillon, “Pandemonium on the Bay: Naval Station Treasure Island and the Toxic Legacies of Atomic Defense,” in Urban Reinventions: San Francisco’s Treasure Island, eds. Lynne Horiuchi and Tanu Sankalia (Honolulu: University of Hawaii Press, 2017), 140–158.
 U.S. Navy, “Treasure Island Naval Station Final Historical Radiological Assessment,” 6-17.
 Ibid., 6-9.
 Jack Foisie, “Radioactive Navy Building Now Cooling Off,” San Francisco Chronicle (March 12, 1950).
 Jack Foisie, “Geiger Counter Sleuths Go After Spilled Radium,” San Francisco Chronicle (January 26, 1950).
 U.S. Navy, “Treasure Island Naval Station Final Historical Radiological Assessment,” 6-6—6-8.
 U.S. Navy, “Treasure Island Naval Station Final Historical Radiological Assessment – Supplemental Technical Memorandum,” 5–6.
 David S. Sorenson, Shutting Down the Cold War: The Politics of Military Base Closure (New York: St. Martin’s Press, 1998).
 United States Congress, Superfund Amendments and Reauthorization Act of 1986, https://www.govtrack.us/congress/bills/99/hr2005. To comply with these new legal requirements, the Department of Defense initiated the Installation Restoration Program (IRP) and Defense Environmental Restoration Program (DERP). The BRAC program was later integrated into these programs.
 United States Department of the Navy, “Initial Assessment Study of Hunters Point Naval Shipyard (Disestablished) – San Francisco, California,” (October 1984), https://www.bracpmo.navy.mil/content/dam/bracpmo/california/former_naval_shipyard_hunters_point/pdfs/all_documents/environmental_documents/radiological/1984_HPNS_Initial_Assessment_Study_Disestablished)_Report.pdf. Triple A Machine Shop was also responsible for illegally dumping PCBs, solvents, paint, and other chemicals at the shipyard. In 1992, Triple A was fined $9.2 million for violating the California Hazardous Waste Control Act, the largest fine for toxic dumping in the state at the time. See Jim Herron Zamora and Jane Kay, “Triple A Machine Shop Toxics Case,” SFGate (December 9, 1996), https://www.sfgate.com/news/article/TRIPLE-A-MACHINE-SHOP-TOXICS-CASE-3110790.php.
 CERCLA requires the Navy to remediate contamination on the shipyard to an excess lifetime cancer risk of one-in-ten-thousand to one-in-a-million, and a Noncancer Hazard Index of less than 1.
 The original remedy was based on the “spill model,” which assumed that high levels of contamination are found near the center of a release with levels decreasing outward. In the course of the remediation, however, the Navy discovered widespread distribution of metals such as manganese and arsenic. The Navy concluded that these “ubiquitous metals” were naturally-occurring in the fill material that was used to expand the shipyard in the 1940s. Additionally, the Navy discovered high levels of volatile organic compounds (VOCs) in the soil and groundwater, which it concluded resulted in a greater health risk due to changes in toxicity estimates.
 United States Department of the Navy, “Final Amended Parcel B Record of Decision – Hunters Point Shipyard, San Francisco, California” (January 14, 2009). These controls include environmentally restrictive covenants on land use and the prohibition of growing vegetables or fruit in the soil for consumption.
 City and County of San Francisco, “Proposition P: Hunters Point Clean-Up” (November 7, 2000), https://webbie1.sfpl.org/multimedia/pdf/elections/November7_2000.pdf.
 United States Department of the Navy, “Final Base-Wide Radiology Removal Action, Action Memorandum – Revision,” (April 21, 2006), https://www.bracpmo.navy.mil/content/dam/bracpmo/california/former_naval_shipyard_hunters_point/pdfs/all_documents/environmental_documents/radiological/hps_200604_memo_rad.pdf. Soil and other materials found to be radioactive are disposed at a licensed low-level radioactive waste facility at Clive, Utah. Waste with chemical contamination is disposed of at hazardous waste facilities, such as the one located at Kettleman City in San Joaquin Valley.
 Jason Fagone and Cynthia Dizikes, “At tainted San Francisco shipyard, is ‘safe’ site really safe?,” San Francisco Chronicle (May 6, 2018), https://www.sfchronicle.com/bayarea/article/At-tainted-San-Francisco-shipyard-is-safe-12891168.php?psid=3QfTj. The scandal has raised fears that contaminated soil was erroneously declared clean and disposed of in non-hazardous waste landfills, such as the Keller Canyon Landfill in Pittsburg.
 The EPA, DTSC, and CDPH expressed even further uncertainty over the data, finding 90 percent of samples in Parcel B and 97 percent in Parcel G to be unreliable.
 Tetra Tech is now facing a $27 billion class action lawsuit from Bayview-Hunters Point residents. In 2018, the U.S. Department of Justice announced its intention to join the whistleblower lawsuit against Tetra Tech.
 Daniel Hirsch, et al., “Hunters Point Naval Shipyard: The Nuclear Arms Race Comes Home,” Committee to Bridge the Gap (October 2018), http://committeetobridgethegap.org/hunters-point-reports/HuntersPointReport1.pdf.
 Daniel Hirsch, et al., “The Great Majority of Hunters Point Sites Were Never Sampled for Radioactive Contamination: And the Testing That Was Performed Was Deeply Flawed,” Committee to Bridge the Gap (October 2018), http://committeetobridgethegap.org/wp-content/uploads/2018/10/HuntersPointReport2.pdf.
 Daniel Hirsch, et al., “Hunters Point Shipyard Cleanup Used Outdated and Grossly Non-Protective Cleanup Standards,” Committee to Bridge the Gap (October 2018), http://committeetobridgethegap.org/wp-content/uploads/2018/10/HuntersPtReport3CleanupStandards.pdf.
 Daniel Hirsch, et al., “From Cleanup to Coverup: How the Navy Quietly Abandoned Commitments to Clean Up Hunters Point Naval Shipyard and is Instead Covering Up Much of the Contamination,” Committee to Bridge the Gap (August 2019), http://committeetobridgethegap.org/hunters-point-reports/FromCleanupToCoverup.pdf.
 The environmental contamination at Hunters Point has given rise to numerous lawsuits. In 1994, a coalition of environmentalist and public interest groups sued the U.S. Navy for contamination at the shipyard, which plaintiffs claimed violated the Clean Water Act. More recently, Tetra Tech has become the target of lawsuits led by Bayview-Hunters Point residents, shipyard homeowners, and former city employees working at the shipyard.
 Jennifer Liss Ohayon, “Addressing Environmental Risks and Mobilizing Democracy?: Policy on Public Participation in U.S. Military Superfund Sites,” in Proving Grounds: Militarized Landscapes, Weapons Testing, and the Environmental Impact of U.S. Bases, ed. Edwin A. Martini (Seattle: University of Washington Press, 2015), 175–210.
 “EPA Faults Navy Handling of 4-Week Landfill Fire,” Los Angeles Times (September 12, 2000), http://articles.latimes.com/2000/sep/12/news/mn-19730.
 Jason Fagone and Cynthia Dizikes, “Limited scope of testing at SF shipyard housing area leaves site’s safety in doubt,” San Francisco Chronicle (February 21, 2019), https://www.sfchronicle.com/green/article/Limited-scope-of-state-testing-in-shipyard-13632243.php.
 Jason Fagone and Cynthia Dizikes, “SF’s Treasure Island, poised for building boom, escaped listing as Superfund site,” San Francisco Chronicle (September 19, 2019), https://www.sfchronicle.com/bayarea/article/SF-s-Treasure-Island-poised-for-building-boom-14451339.php.
 U.S. Navy, “Treasure Island Naval Station Final Historical Radiological Assessment.”
 Earlier soil excavations to remove chemical contamination were not radiologically screened prior to being disposed offsite at hazardous waste facilities.
 U.S. Navy, “Treasure Island Naval Station Final Historical Radiological Assessment – Supplemental Technical Memorandum.”
 United States Department of Navy, “Final Survey Completion Report: Radiological Scoping Surveys of Installation Restoration Site 12 Housing Units – Former Naval Station Treasure Island, San Francisco, California,” (February 2015), https://www.bracpmo.navy.mil/content/dam/bracpmo/california/former_naval_station_treasure_island/pdfs/environmental/hra/TI_2015_Final_Survey_Completion_Report_RAD_Scoping%20Surveys_of_IR_Site12_Housing_units_PART_1of_9.pdf.
 Matt Smith and Katharine Mieszkowski, “Treasure Island cleanup exposes Navy’s mishandling of its nuclear past,” Bulletin of the Atomic Scientists 70, no. 3 (2014): 65–78, https://doi.org/10.1177/0096340214531186.
 Jason Fagone and Cynthia Dizikes, “Suspect Hunters Point shipyard contractor did similar work at Treasure Island,” San Francisco Chronicle (February 19, 2019), https://www.sfchronicle.com/bayarea/article/Suspect-Hunters-Point-shipyard-contractor-did-13626062.php.
 Office of Community Investment and Infrastructure (OCII), “Hunters Point Shipyard Redevelopment Plan – Amended” (July 16, 2018), https://sfocii.org/sites/default/files/Documents/Project%20Areas/HPSY/Phase%202%20%26%20Candlestick/Hunters%20Point%20Shipyard%20Redevelopment%20Plan%202018%20Amendment%20FINAL%20.pdf.
 OCII, “Hunters Point Shipyard Redevelopment Plan – Amended.” This general plan has remained intact with some changes. The 2007 integration of the Hunters Point Shipyard and Candlestick Point redevelopment plans was intended to facilitate the construction of a new stadium for the 49ers before they decided to move to Santa Clara. In 2018, the OCII amended the redevelopment plan to scrap the stadium plan and increase the amount of retail, commercial, office, and research and development space. These changes increased the projected revenues from the project. In 2019, Lennar announced plans to scrap a mall at Candlestick Point owing to the decreasing profitability of retail.
 Lennar Corporation, “Core Community Benefits Agreement: Hunters Point Shipyard/Candlestick Point Integrated Development Project,” (May 30, 2008), https://d10benefits.org/wp-content/uploads/2013/01/lennar_ad10_ccba_executed-1.pdf.
 Port of San Francisco, “Blue Greenway: Planning and Design Guidelines,” (July 2012), https://sfport.com/sites/default/files/FileCenter/Documents/8344-BG_DesignGuidelines%20%282%29.pdf.
 Lauren Smiley, “The Man Who Cried Dust,” SF Weekly (July 1, 2009), https://archives.sfweekly.com/sanfrancisco/the-man-who-cried-dust/Content?oid=2173187.
 Lindsey Dillon, “The Breathers of Bayview Hill: Redevelopment and Environmental Justice in Southeast San Francisco,” Hastings Environmental Law Journal 24, no. 2 (January 2018): 227–236, https://repository.uchastings.edu/cgi/viewcontent.cgi?article=1417&context=hastings_environmental_law_journal.
 Treasure Island Development Authority (TIDA), “Treasure Island and Yerba Bueno Design for Development” (June 28, 2011), https://sftreasureisland.org/ftp/devdocs/D4D/12282011_FinalTI%20D4D%28Date06282011%29.pdf.
 John Coté and Rachel Gordon, “Deal on transfer of Treasure Island,” SFGate (August 18, 2010), https://www.sfgate.com/bayarea/article/Deal-on-transfer-of-Treasure-Island-3177476.php.
 On sustainability discourses surrounding Treasure Island, see Tanu Sankalia, “Visions of an Island Ecotopia,” in Urban Reinventions: San Francisco’s Treasure Island, eds. Lynne Horiuchi and Tanu Sankalia (Honolulu: University of Hawaii Press, 2017), 187–210.
 In 2014, the California Cancer Prevention Institution concluded that Treasure Islanders did not experience higher-than-expected cancer rates based off an analysis of data from the Bay Area Cancer Registry. However, the small population size and the relatively short time that most residents have lived on the island make these findings far from conclusive.